Epstein Secrets

ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o

uses the witness from having to answer questions that call for responses covered by the privilege. See Roe I Slotnick , 781 F.2d 238 (2d Cir. 1986); McKay I C.I.R. , 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on t

1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH ICELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001

in exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that auJant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 1.J1 Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who w

tem. I would grant both petitions to admit to bail pending appeal. SEYMOUR, Circuit Judge, dissenting. I generally agree with most of what Judge McKay has written and I therefore join his dissent. I write separately to note two things. First, I am not convinced that likelihood of flight is the so

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

uses the witness from having to answer questions that call for responses covered by the privilege. See Roe v. Slotnick, 781 F.2d 238 (2d Cir. 1986); McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on